Justia Massachusetts Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted on two indictments charging murder in the first degree on theories of deliberate premeditation, extreme atrocity or cruelty, and felony-murder. The jury also found Defendant guilty of several related offenses. The Supreme Court affirmed Defendant's convictions, holding (1) the trial court erred in admitting certain statements Defendant made to police, but the statements' admission did not result in a substantial likelihood of a miscarriage of justice; (2) the prosecutor's failure to timely disclose that a key witness had been unable to identify Defendant at voir dire violated Defendant's constitutional rights, but Defendant was not prejudiced by the delay; and (3) defense counsel was not ineffective for failing to move to suppress the admission of evidence obtained by Massachusetts police based on a pawn ticket that had been seized by New Jersey police after Defendant's arrest. View "Commonwealth v. Santana " on Justia Law

After a jury trial, Defendants were convicted of murder in the first degree on a theory of extreme atrocity or cruelty, assault by means of a dangerous weapon, and related offenses for shootings that took place on a subway train. The Commonwealth's theory at trial was that the shootings had been committed as part of a joint venture. The Supreme Court affirmed, holding, inter alia, (1) there was sufficient evidence of joint venture; (2) the trial court did not prejudicially err in refusing to severe Defendants' trials; (3) the trial court correctly instructed the jury on joint venture and murder in the first degree on a theory of extreme atrocity of cruelty; (4) the prosecutor made an improper statement during closing arguments, but the improper remark did not make a difference in the jury's conclusions; and (5) the trial court did not abuse his discretion in admitting evidence of Defendants' gang affiliation. View "Commonwealth v. Akara" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on the theories of deliberate premeditation and extreme atrocity or cruelty and of larceny of a motor vehicle. The Supreme Court affirmed Defendant's convictions and declined to exercise its power to grant relief under Mass. Gen. Laws ch. 278, 33E with respect to the conviction of murder in the first degree, holding (1) the trial court did not err in partially denying Defendant's motion to suppress evidence seized during a search of Defendant's apartment; (2) the prosecutor did not include improper remarks in his opening statement; (3) the trial judge did not err in refusing to strike an answer by a Commonwealth witness concerning the meaning of "inconclusive" DNA test results; (4) the judge did not err in refusing to allow the Defendant's counsel to cross-examine a witness about specific acts of prior misconduct; (5) the prosecutor made an improper remark in closing arguments, but the remark was harmless; (6) evidence that the death was a homicide was properly introduced; and (7) because the evidence was sufficient to support the verdict, the trial court did not err by denying Defendant's motion for a required finding of not guilty. View "Commonwealth v. Almonte" on Justia Law

Plaintiffs were individuals who lived in New York and worked there as couriers for Defendant, a corporation headquartered in Massachusetts. Plaintiffs brought this action in a Massachusetts court to enforce certain Massachusetts independent contractor, wage, and overtime pay statutes. The superior court dismissed the complaint, concluding (1) the Massachusetts independent contractor statute does not apply to non-Massachusetts residents working outside Massachusetts, and (2) as independent contractors, Plaintiffs failed to state claims under the Massachusetts wage statutes. The Supreme Court vacated the judgment of dismissal and remanded for further proceedings, holding that, insofar as the written contract between the parties contained an enforceable clause requiring both that actions be brought in Massachusetts and requiring that the contract and all rights and obligations of the parties be determined under Massachusetts law, and where application of Massachusetts law is not contrary to a fundamental policy of the jurisdiction where the individuals live and work, it was error to dismiss Plaintiffs' complaint. View "Taylor v. E. Connection Operating, Inc." on Justia Law

Defendant pleaded guilty to possession of child pornography, requiring him to register as a sex offender. Defendant was placed on probation by a superior court judge. Upon Defendant's motion seeking relief from the requirement that he register as a sex offender, the sentencing judge concluded that Defendant had demonstrated that he did not pose a risk of reoffense or a danger to the public and relieved him of the registration requirement. Almost three years later, a second superior court judge found Defendant in violation of his probation and, on that basis, ordered Defendant to register with the Sex Offender Registry Board. The Supreme Court reversed, holding that, under the terms of the Sex Offender Registry Act, the second judge was without authority to require registration as a sex offender as a condition of probation or to revoke the prior grant of relief from registration. View "Commonwealth v. Ventura" on Justia Law

After a jury trial, Defendant was convicted of indecent assault and battery on a child under the age of fourteen years and rape of a child under the age of sixteen years. Defendant unsuccessfully moved for a judgment notwithstanding the verdict, arguing that his conduct underlying the conviction of indecent assault and battery was not separate and distinct from his conduct constituting statutory rape because the moving of the victim's clothing was necessary to the rape. The Supreme Court vacated Defendant's conviction of indecent assault and battery on a child under fourteen and affirmed his conviction of rape of a child under sixteen, holding that Defendant's actions underlying the two convictions were not separate and distinct. View "Commonwealth v. Suero" on Justia Law

After falling down a staircase at a bar and restaurant in Boston, a college student died. Plaintiffs, the student's parents, filed this action against the restaurant and trustees of a trust that owned the land and buildings within which the restaurant operated. The complaint alleged claims against the restaurant and trustees for wrongful death and for violation of Mass. Gen. Laws ch. 93A. Plaintiffs based their chapter 93A claim on Defendants' alleged building code violations, which Plaintiffs claimed constituted unfair or deceptive conduct. A jury returned a verdict for Defendants on Plaintiffs' wrongful death claims, and the trial judge found in favor of Plaintiffs on the chapter 93A claim, finding that the student fell and suffered a fatal injury because the stairs were in an unsafe, defective condition having been rebuilt without necessary building permits. The Supreme Court vacated the judgment, holding that Plaintiffs were entitled to recover on their chapter 93A claim but that the judge erred in her calculation and award of damages. Remanded. View "Klairmont v. Gainsboro Rest., Inc." on Justia Law

Plaintiff was injured when he unsuccessfully tried to flip into an inflatable pool from a trampoline that had been set up directly adjacent to the pool in the backyard of a property he was renting from Defendants. Plaintiff filed a claim for negligence against Defendants for setting up and maintaining the trampoline next to the pool and for failing to warn him of the danger of jumping from the trampoline into the pool. The trial court ruled in favor of Defendants. The appeals court affirmed. The Supreme Court reversed, holding (1) a landowner has a duty to remedy an open and obvious danger where he has created and maintained that danger with the knowledge that lawful entrants would choose to encounter it despite the obvious risk of doing so; and (2) the judge erred in instructing the jury to cease deliberations if they concluded that the danger was open and obvious, and should have further instructed the jury that a landowner is not relieved from remedying open and obvious dangers where he can or should anticipate that the dangerous condition will cause physical harm to the lawful entrant notwithstanding its known or obvious danger. View "Dos Santos v. Coleta" on Justia Law

Defendant pleaded guilty to rape of a child and indecent assault and battery. When Defendant, who was homeless, failed to appear at the local police department to verify his registration information, the Commonwealth charged him by complaint with failing to verify his registration information. Defendant pleaded guilty to the charge. The trial judge sentenced Defendant to thirty days committed with no community parole supervision for life (CPSL). The Commonwealth subsequently filed a petition asking the county court to compel the judge to sentence Defendant to CPSL as mandated by Mass. Gen. Laws ch. 6, 178H. A single justice of the Supreme Court allowed the petition and remanded to the trial court for further proceedings. On appeal, the Commonwealth agreed that the case was insufficient to support the imposition of CPSL but argued that by pleading guilty, Defendant waived his right to raise any argument about the sufficiency of the complaint on that point. The Supreme Court reversed the judgment of the single justice, holding that Defendant did not waive his argument concerning the insufficiency of the complaint on the CPSL issue by pleading guilty. View "Commonwealth v. Batista" on Justia Law

Defendants owned two-family and three-family rental properties in the City of Worcester. Defendants leased dwelling units in these properties to groups of four unrelated adult college students. The City determined that, where such a dwelling unit is occupied by four or more unrelated adults not within the second degree of kindred to each other, the dwelling unit is a "lodging" for purposes of the Lodging House Act, and Defendants were therefore operating a lodging house without a license. The trial court found Defendants in contempt and imposed monetary fines. The appeals court affirmed. The Supreme Court reversed, holding that the dwelling units did not meet the definition of "lodgings" under the Act, and accordingly, the properties were not lodging houses under the Act. View "City of Worcester v. College Hill Props., LLC" on Justia Law